U.S. Department of Justice

Office of Community Oriented Policing Services

COPS Manual

COPS MORE 2000

Grant Owner's Manual

A step-by-step guide

to assist law enforcement agencies

in carrying out and reporting on

their Tribal Resources Grant Program grant

COPS MORE 2000

Grant Owner's Manual

The following manual was created to assist COPS MORE (Making Officer Redeployment

Effective) 2000 grantees with the administrative and financial matters associated with the

grant.

For more information about your MORE 2000 grant, contact your COPS Grant Program

Specialist. If you do not know who your Grant Program Specialist is, or do not know the telephone number of your Grant Program Specialist, contact the U.S. Department of Justice

Response Center at 1-800-421-6770.

U.S. Department of Justice 

Office of Community Oriented Policing Services

1100 Vermont Avenue NW

Washington, DC 20530

(For overnight delivery, please use 20005 as the zip code.)

COPS Office Internet web site: http://www.usdoj.gov/cops/

COPS MORE web site: http://www.cops.usdoj.gov

i

Contents

Getting Started ................................................................................................................iii

Glossary of Terms ............................................................................................................v

I. Grant Acceptance, Terms and Conditions ..........................................................3

The Award Page

What is a Modified Award?

Grant Conditions

Reasons for Grant Conditions

Review of Each Condition

How to Accept the Award

Who Should Sign the Award for my Agency?

When do the Grant Materials Need to be Returned?

What are the Specific Rules Regarding Termination of Grant Funding?

Changes in Your Grant

Renewing / Extending Your Grant

Questions About Accepting the Grant

II. Accessing Grant Funds ...........................................................................................17

Payment Methods

A. PAPRS - Phone Activated Paperless Request System

How do we set up a PAPRS account?

B. LOCES - Letter of Credit Electronic Certification System

What are the benefits of LOCES?

Setting up Your Account

How do I fill out the payment enrollment forms?

Do I need a Financial Status Report to open my account?

Additional Payment Questions

Can we receive advances?

How often do we request reimbursement of costs?

Can we earn interest on our grant funds?

III. Meeting the Local Match .....................................................................................23

Payment Sources for Matching Funds 

Should I maintain records of the match?

Waivers

Can the matching requirements be waived?

How are waivers granted?

How are we notified whether or not a waiver was granted?

How do we appeal the denial of a waiver?

IV. Financial Record Maintenance ...........................................................................27

Accounting Systems

What accounting systems are needed?

What records should be kept?
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COPS MORE 2000 Grant Owner’s Manual

How long should documents be kept?

What if we have more than one grant?

Who may access our records?

V. Federal Audit Requirements ................................................................................31

Audit Requirements

Who must have an audit?

What is a "single act audit"?

What is the purpose of a single act audit?

What are the audit reporting requirements?

What is the due date of a single act audit reports?

Where are the audit reports to be submitted?

What if there are problems with our audit report?

How are audit requirements monitored?

How can our agency receive technical assistance with audit

requirements?

What are the consequences of not complying with audit

requirements?

VI. Reports.....................................................................................................................39

Program Progress Reports

How often will progress reports be requested?

What kind of information will be requested?

How and when will these forms be sent?

Financial Status Reports

How will grant funds be monitored?

How do I file Financial Status Reports under PAPRS?

How do I file financial status reports under LOCES?

Cash Reconciliation Reports

Telephone Calls About Redeployment

How often will calls be made?

What will be asked during the telephone contact?

How to Report Violations (Fraud, Waste and Abuse)

VII. When The Grant Period Ends ..............................................................................43

Grant “Close Out”

Final Financial Status Report

When should all the grant monies be spent?

Final Progress Report

Conclusion.......................................................................................................................44

Appendices .....................................................................................................................47

A. List of Source Documents

B. Assurance and Certificatons

iii

Getting Started

Congratulations on receiving a grant from the Office of Community Oriented Policing

Services (COPS). Your COPS MORE 2000 grant provides funding directly to local,

state and tribal jurisdictions for the procurement of support resources. COPS MORE

2000 was designed to expand the implementation of community policing through the

redeployment of existing officers, rather than by hiring or rehiring additional law

enforcement officers.

This COPS MORE 2000 Grant Owner's Manual will assist you with the administrative

and financial matters associated with your grant. It was developed by the COPS Office

in conjunction with COPS Accounting Operations to ensure that all COPS MORE 2000

grantees clearly understand and meet the requirements of their grants. Please do not

hesitate to call the COPS Office through the Department of Justice Response Center at

1-800-421-6770 if you need assistance with the implementation of your grant.

Thank you for providing us with the opportunity to work in partnership with your

community.

For assistance, call the COPS Office

at 1-800-421-6770.

v

Glossary of Terms

Allowable Costs

Allowable costs are costs that will be paid for by this grant program. COPS MORE

2000 provides funding for support resources (salaries and fringe benefits of nonsworn civilian personnel). Upon review of your submitted budget, any non-allowable

costs were removed and your total budget amount was revised accordingly. A copy of

the budget clearance memorandum from COPS Accounting Operations identifying

these revisions is included in your award package.

Authorized Official 

The authorized official is the individual in your organization who has final responsibility for all programmatic and financial decisions regarding this grant award.

Award Start Date

This is the date on or after which your agency is authorized to spend funds to hire

civilian personnel. This date is found on your original award document. Grantees

may not expend funds or hire civilians prior to this date.

Catalog of Federal Domestic Assistance (CFDA)

The CFDA is a government-wide publication orchestrated by the General Services

Administration. The CFDA contains a description and index of all forms of Federal

assistance available from the Federal government. Each program is assigned a "CFDA

number," which is used by auditors in tracking grant revenues under the Single Audit

Act. It is also used in participating states by state Single Points of Contact for intergovernmental reviews under Executive Order 12372. The COPS MORE 2000 CFDA

number is 16.710.

Cognizant Federal Agency 

Your Cognizant Federal Agency is generally the Federal agency that provides you with

the most Federal money. Your Cognizant Federal Agency may have already been

assigned to you by the Office of Management and Budget. If this is the first Federal

grant that your organization has received, the U.S. Department of Justice (DOJ) is your

Cognizant Federal Agency. Your Single Audit Act reports should be sent to the U.S.

Department of Justice's Clearinghouse at:

Single Audit Clearinghouse

Bureau of Census

1201 E. 10th Street

Jeffersonville, IN 47132
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COPS MORE 2000 Grant Owner’s Manual

COPS Accounting Operations

COPS Accounting Operations handles your financial and budgetary needs related to

the COPS MORE 2000 grant. There is a staff accountant assigned to your state who is

available to answer any questions that you may have concerning the financial aspects

of your COPS MORE 2000 grant. To identify your staff accountant, refer to the Budget

Clearance Memorandum enclosed in your award package, or call the U.S. Department

of Justice Response Center at 1-800-421-6770.

COPS Office 

The Office of Community Oriented Policing Services (COPS) is the division of the U.S.

Department of Justice that is your "grantor agency" for your COPS MORE 2000 grant.

The COPS Office is responsible for administering your grant for the entire grant period. You can reach the COPS Office at 1-800-421-6770

FTE (Full-time Equivalent) 

The COPS Office uses a full-time equivalent standard of 1824 hours (228 shifts) per

year to calculate redeployment.

Grant Number

For grants awarded in Fiscal Year 2000, this number is in the following format:

2000-CL-WX-0000 or 2000-CM-WX-0000. This number can be found in the upper

right-hand corner of your Award Page. It is assigned by COPS Accounting

Operations, and should be used when corresponding with that department. This

will aid the accounting staff in determining to which grant you are referring.

Matching Funds

Under the COPS MORE 2000 program, unless a waiver has been granted because of

severe fiscal distress, the COPS Office provides up to 75 percent of the cost of salaries

and fringe benefits of civilian personnel for one year. COPS MORE 2000 grantees are

responsible for a cash match of at least 25 percent of the total cost of allowable items.

The source of your agency's local match cannot be from any funds previously budgeted for law enforcement purposes. See "Meeting the Local Match," Section III of

this manual, for more information.

Obligation of Funds

Federal funds are considered "obligated" when the grant award document is signed

by the Director of the COPS Office or his designated official. Funds are reserved

against the grant until all the grant monies are spent or refunded to the Federal government. Local funds are considered "obligated" when the salaries and benefits of the

non-sworn civilians have been paid or will be paid for work performed by the civilians.
vii

Glossary of Terms

OJP EIN Number / Vendor Number

This number is your agency's nine-digit Federal tax identification number assigned to

you by the IRS. Your accounting/bookkeeping department should have this number.

In some cases, the EIN has been previously assigned to another agency within your

jurisdiction. In that instance, a new vendor number will be assigned to you by the

COPS Office. The new assigned number is to be used for administrative purposes only

and should not be used for IRS purposes.

ORI Number (Originating Agency Identifier)

This number is assigned by the FBI, and it is your agency's identifier. The first two letters are your state abbreviation, the next three numbers are your county's code, and

the final two numbers identify your jurisdiction within the county. It can be located

in the upper right-hand of your grant award document. When you contact the COPS

Office with a question, you can provide the ORI number or your grant number and we

will be able to assist you.

The Public Safety Partnership and Community Policing Act of 1994 

The COPS Office is charged with fulfilling the mandates of this law. The purposes of

the law are to:

• Substantially increase the number of law enforcement officers interacting 

with members of the community;

• Provide additional and more effective training to law enforcement officers to

enhance their problem solving, service and other skills needed in interact

ing with members of the community; 

• Encourage the development and implementation of innovative programs to

permit members of the community to assist law enforcement agencies in the

prevention of crime; and

• Encourage the development of new technologies to assist law enforcement 

agencies in reorienting the emphasis of their activities from reacting to 

crime to preventing crime.

Redeployment 

Redeployment refers to sworn officers currently employed by the grantee who will be

able to initiate or enhance community policing as a direct result of the procurement

of the civilian personnel.

Supplanting

For the purpose of your COPS MORE 2000 grant, supplanting means replacing state

or local funds which otherwise would have been spent on law enforcement purposes

with Federal COPS funds. You are prohibited from supplanting throughout the grant

period. This means that you may not use COPS funds to pay for any non-sworn civilian who otherwise would have been employed with state or local funds regardless of

the COPS program. COPS funds must instead be used to supplement your law

enforcement budget. For further information, please contact the COPS Office Legal

Division at 202-514-3750.
viii

COPS MORE 2000 Grant Owner’s Manual

Support Resources 

Non-sworn personnel funded under this grant must result in the redeployment of currently employed, sworn officers to initiate or enhance community policing efforts.
Grant Acceptance, Terms, and Conditions

COPS MORE 2000

Grant Owner’s Manual

Section1

3

Grant Acceptance, Terms, and Conditions

I. Grant Acceptance, Terms, 

and Conditions

In order to officially begin your grant, you will need to review the Award Page and

grant conditions, sign the Award Page or Modified Award Page, and return the original to:

COPS MORE 2000 Control Desk

Office of Community Oriented Policing Services (COPS)

1100 Vermont Avenue NW, 7th Floor

Washington, DC 20530

The Award Page

The Award Page is the one-page, double-sided document indicating your official grant

funding amount, the award number, the award date, the grant time period and the

required level of redeployment (FTE).

The award date for your COPS MORE 2000 grant can be found on the Award Page.

The Federal share of any allowable costs you incur on or after the award date will be

reimbursed. The duration of your COPS MORE 2000 grant is one year.

Your grant award number is in the following format: 2000-CL-WX-0000 or 2000-CMWX-0000. If you have any questions regarding your grant, please refer to your grant

award number or your agency's ORI number when calling for assistance. Both can

be found on your Award Page.

The Award Page is preprinted with your law enforcement and government officials'

names and addresses. If this information is incorrect or has changed, please correct

it on the enclosed change of information page and mail it to your Grant Program

Specialist.

What is a Modified Award?

In a small number of cases, a Modified Award Page may be included in this mailing.

The final grant amount on this document may differ from the estimated amount on

your original Award Page, because the final grant amount is based upon your

approved budget. If you are receiving a Modified Award, take careful note of the

change between your estimated award amount on the original document and the actual amount on the Modified Award Page. If you have any questions about the modification, refer to your budget clearance memorandum. If you still have questions,

please contact COPS Accounting Operations. After you review and understand the
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COPS MORE 2000 Grant Owner’s Manual

award document, please sign, make a copy for your records, and mail the original

with your payment selection sheet to the COPS Office.

Grant Conditions

The grant conditions are the terms listed on the back of your Award Page. By accepting this grant, you are entering into an agreement with the U.S. Department of Justice,

Office of Community Oriented Policing Services (COPS). As part of that agreement,

you agree to 13 grant conditions (and possibly additional conditions specific to your

agency). The section that follows describes in detail each of the award conditions, its

rationale and its implications. It also addresses many commonly asked questions.

In some cases, your agency may receive a special grant condition. You will be unable

to access your grant funds until you have satisfied this condition. For example, you

will not be able to draw down funds until your budget receives final clearance. If you

receive an award with a budget special condition, your budget has not yet received

final clearance. In those cases, you will receive notification in writing when your special condition has been met. After reviewing your Award Page and other grant documents, it should be clear to you which grant conditions, if any, would prevent drawdowns from being made until those conditions have been satisfied. If you have any

questions about these conditions, please call your Grant Program Specialist.

Reasons for Grant Conditions

The requirements of your COPS MORE 2000 grant are established within:

• The Public Safety Partnership and Community Policing Act of 1994, under 

which the COPS Office was established; and

• Applicable rules, regulations and policies issued by the U.S. Department of

Justice (DOJ), Office of Management and Budget (OMB), the General 

Accounting Office (GAO), and the United States Treasury.

A list of source documents for this booklet is provided in Appendix A. You may request

copies of any of these materials from:

Office of Administration, Publication Unit

New Executive Office Building, Room G 236

Washington, D.C. 20503

or from the COPS Office.

Review of Grant Conditions

1. Allowable Costs

The funding under this project is for the payment of additional civilian support personnel approved by the COPS Office.
5

Grant Acceptance, Terms, and Conditions

Rationale: As the program materials state, COPS MORE 2000 is a program that funds

additional civilian personnel that directly contribute to increased community policing

presence through sworn officer redeployment.

Action: Support Resources - To be eligible for payment under the grant, a salary must

be reasonable for the services rendered, and must be paid to a person appointed after

the grant award start date under the law or rules governing hiring by your agency.

Salary payments must be based on payroll records supported by time and attendance

records or their equivalent. The types of records you must keep to document that you

are following this grant condition are described in Section V of this Manual.

Fringe benefits may be paid if they are part of a reasonable compensation package

offered to your employees. Particular items of fringe benefits must fall within the categories authorized by the COPS Office. Authorized fringe benefits include FICA, Social

Security, health insurance, life insurance, vacation, sick leave, retirement, worker's

compensation, and unemployment insurance.

2. Supplementing, not Supplanting

COPS MORE 2000 grant funds must be used to hire one or more civilians

beyond the number of civilians that would be hired or employed by the

grantee in the absence of the grant.

Rationale: The Public Safety Partnership and Community Policing Act of 1994 specifically states that Federal funds under the COPS programs are not to be used to supplant existing local or state funds.

Action: To meet this grant condition, you will need to ensure that:

• Each civilian that you hire under COPS MORE 2000 is newly hired on or 

after your grant award start date. You may not fill the COPS MORE 2000 

position(s) with any civilian who was hired prior to the award start date 

unless an exception is authorized in writing by the COPS Office;

• The civilian(s) that you are hiring brings your civilian force to a number

over and above the number of civilian positions that were budgeted or funded as of the date of your COPS MORE 2000 application, plus any additional

civilian positions budgeted with state or local funds during the grant period;

• During the life of your grant, you must continue to hire as many new, locally funded civilians as you would have if you had not received your grant. You

may not cancel or postpone spending money in your budget that is committed to hiring other new civilians; and 

• You must take positive and timely steps to fill any locally funded vacancies

that were created on or after the date of your grant application by retirement, resignation or other reasons with new locally funded civilians. Again,

any exception must be authorized in writing by the COPS Office.
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COPS MORE 2000 Grant Owner’s Manual

3. Retention

Your agency is expected to implement the retention plan submitted with

your application to retain the civilian positions funded by the COPS MORE

2000 program as well as maintain the resulting level of redeployment. The

COPS Office will monitor retention for one full locally funded budget cycle

after you have achieved the required level of redeployment, which may be

found on your grant award document.

Rationale: The Public Safety Partnership and Community Policing Act of 1994 envisions that newly created civilian positions and required redeployment should be

maintained by localities beyond the Federal funding period.

Action: Your retention plan should focus on maintaining the civilian position(s) and

resulting officer redeployment levels beyond the life of the grant for at least one full

locally funded budget cycle. If, for any reason, the civilian originally filling a position

funded by the COPS MORE 2000 grant leaves your department, it is anticipated that

you will fill the position with a new civilian.

4. Redeployment

The goal of the COPS MORE 2000 program is to reduce the amount of

paperwork and administrative tasks performed by veteran trained officers

so that they can spend more time on the street and in America's neighborhoods. Grants awarded under MORE 2000 are restricted to hiring of civilian personnel that will redeploy officers, or full-time equivalents (FTEs),

and enhance community policing activities within the agency's jurisdiction.

The grantee agrees to monitor, track, and maintain the level of redeployment of current sworn officers that results from the COPS MORE 2000

funding.

Rationale: As the program materials state, COPS MORE 2000 is designed to expand

the time available for community policing by current law enforcement officers. Under

COPS MORE 2000, the expansion of community policing is through redeployment,

rather than by hiring or rehiring additional law enforcement officers.

The time saved through MORE 2000 must result in an increase in the number of officer FTEs redeployed. Redeployment of officer FTEs applies to sworn officers currently employed by the grantee who will be able to enhance community policing activities as a direct result of the hiring of civilian personnel. Any awarded MORE 2000

grant requires that the number of officer FTEs redeployed will be equal to or greater

than the number of officers that would result from a COPS grant for hiring officers.

Action: To meet the redeployment grant condition, applicants must ensure that the

time savings for redeployment that results from COPS MORE 2000 funding enhances

community policing activities. Agencies must plan and track time savings and

assure COPS that, as a result of the grant award, community policing is being

enhanced; however, there is no requirement to devote every hour of time saved to a
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Grant Acceptance, Terms, and Conditions

specific hour of community policing activity. The FTE requirement is located on the

Award Page that was signed by the Director of the COPS Office and accepted by the

grantee's law enforcement and government executives.

Agencies granted an award under the MORE 2000 program are required to plan and

track the time savings and officer redeployment realized from the awarded civilian

personnel. Once the civilian personnel are hired and realizing maximum time savings, grantees must develop a tracking plan, which describes the methodology for

measuring the time savings, and implement actual tracking pursuant to the plan for

each awarded position of varying title. Tracking must continue for at least one full

year from the date that the civilians were declared fully operational. This time is necessary for the agency to achieve the total time savings benefit identified. If necessary,

the COPS Office will work with your agency to ensure that this condition is met. For

assistance in developing your agency's tracking plan you may contact your Grant

Program Specialist, or visit the MORE web site at www.cops.usdoj.gov.

5. Community Policing

The COPS Office is responsible for determining the applicability of grant

awards to the community policing activities that are identified in grant

applications. Community policing activities to be executed by your law

enforcement agency will be identified in your COPS MORE 2000 grant

application and will be approved by the COPS Office before the grant is

awarded.

Rationale: Community policing is a policing philosophy that promotes and supports

organizational strategies to address the causes, and reduce the fear, of crime and

social disorder. This is achieved through problem-solving tactics and communitypolice partnerships. It enhances police professionalism by providing officers with the

skills, technology, and motivation to act innovatively to solve community crime-related problems. 

Action: The COPS Office is responsible for determining the applicability of grant

awards to the community policing activities that are identified in grant applications.

Community policing activities that will be executed by local law enforcement agencies

are identified in grant applications and approved by the COPS Office before grants are

awarded. Subsequent changes to community policing activities should be included in

programmatic progress reports. Significant changes to the community policing activities identified in a grant application must be submitted in writing to the COPS Office.

Changes are "significant" if they deviate from the range of possible community policing activities identified and approved in your grant application.

6. Contracts With Other Jurisdictions

a. Civilians funded under this grant may only be involved in activities or

perform services that exclusively benefit your agency and the population

that it serves
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COPS MORE 2000 Grant Owner’s Manual

Rationale: Occasionally, small towns enter into contracts with county or state law

enforcement agencies for law enforcement services. When a small town uses civilian

services from a local police department or sheriff's office, the small town must ensure

that the activities of the civilian are in accordance with the terms and conditions of its

COPS MORE 2000 grant.

Action: The civilian services that have been funded under the MORE 2000 program

cannot be hired out by your agency to other agencies unless they will benefit the population that you serve. If, for example, you are a sheriff's department serving a county with eight small towns, you may contract with one of those small towns to provide

them with the services of a COPS MORE 2000 civilian, provided such a contract is

done in accordance with all of the rules and regulations laid out in this Manual. You

may not, however, offer this COPS MORE 2000 civilian to a neighboring county. 

b. If your agency receives police services through a contractual arrangement, your agency is responsible for ensuring that the hiring of the civilians results in sworn officer redeployment within your jurisdiction.

Rationale: When a small town which contracts for law enforcement services receives

a COPS MORE 2000 grant for civilian personnel, the small town must ensure that the

hiring of the civilian position(s) results in sworn officer redeployment within the

small town's jurisdiction.

Action: If you are a small town grantee and you contract with a law enforcement

agency, you must use the civilian in a manner that will result in the redeployment of

sworn officers within your jurisdiction.

7. Assurances and Program Guidlines

The grantee acknowledges its agreement to comply with the assurances and

certifications submitted with the COPS MORE 2000 application.

Rationale: Although the U.S. Department of Justice has made every effort to simplify

the process for applying for and receiving grants, provisions of Federal law require us

to seek your certification regarding certain matters. Most of these assurances apply

to all grants provided by the Federal government.

Action: When you submitted your original application, there was a list of assurances

that you signed and included with your completed application. This condition merely restates your agreement to comply with those assurances. 

Another copy of the assurances is contained in Appendix B of this Manual. If you have

any questions about them, please contact your Grant Program Specialist.
9

Grant Acceptance, Terms, and Conditions

8. Reports

In order to assist the COPS Office in the monitoring of your award, your

agency will be responsible for submitting progress reports and quarterly

Financial Status Reports. As those reports come due, your Grant Program

Specialist and staff accountant can assist you with these forms and information necessary for compliance

Rationale: The Public Safety Partnership and Community Policing Act of 1994 and

other Federal regulations and policies require that financial assistance provided by

the Federal government be monitored carefully to ensure the proper use of Federal

funds. In addition, the COPS Office seeks to document, on a continuing basis, the

progress of our programs and our grantees.

Action: To meet this condition, you will be required to complete a baseline survey

(the Community Policing Information Worksheet that was included in your application kit), and fill out at least one programmatic progress report during the course of

your COPS MORE 2000 grant, as well as quarterly Financial Status Reports. These

reports are discussed extensively in Section VI.

9. Extensions

Requests for extensions of the grant award period that merely involve additional time, not additional funding, should be submitted in writing to your

Grant Program Specialist not earlier than 90 days before the end of your

grant period. [For information on renewing grant funding, refer to the section of this Manual entitled "Renewing/Extending Your Grant."] 

Rationale: Under Federal regulations, grant extensions that merely request additional time, not additional funding, require prior approval. Without an approved extension, your funding will be automatically stopped at the end of the grant period.

Action: In an effort to reduce the number of extensions given during the grant period, the COPS Office asks that you delay any request for an extension until you are well

into your grant and are able to determine accurately when you expect all grant conditions and redeployment to be met and all grant funds to be drawn down. When the

COPS Office receives and approves your extension request, we will ensure that you

have continued access to your grant monies.

10. Evaluation

The COPS Office may conduct or sponsor national evaluations of the

Community Oriented Policing Services (COPS) Program and the COPS

MORE 2000 program. The grantee agrees to cooperate with the evaluators.

Rationale: The Public Safety Partnership and Community Policing Act of 1994 states

that evaluations of the program may be carried out or commissioned by the Attorney
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COPS MORE 2000 Grant Owner’s Manual

General for the furtherance of the purposes of the Act. The COPS Office plans to conduct evaluations to determine what programs are working, how programs may be

improved, and why certain programs are working better than others.

Specifically, the COPS Office may assess the way in which you implement your community policing program. In some jurisdictions, COPS staff may study the effectiveness of funded programs, projects and activities. Evaluators may collect information

about the programs' effect on crime, victims of crime, and the quality of life in communities. In addition, they may ask questions about how residents feel about community policing and how police feel about their work. This information will be useful to other communities and police agencies across the country.

Action: When evaluations are undertaken, you may be contacted in writing with specific requests for information. In general, evaluators may need to speak with individuals in your department, observe activities of your department, and obtain written

reports about and from your department. You will be asked to facilitate any site visits and information-gathering activities. In addition, you will be asked to provide

accurate and timely information about your grant activities.

11. Grant Owner’s Manual

The grantee agrees to abide by the terms, conditions, and regulations as

found in the COPS MORE 2000 Grant Owner's Manual and the Uniform

Administrative Requirements for Grants and Cooperative Agreements to

State and Local Governments, 28 C.F.R. Part 66.

Rationale: This Manual has been tailored to inform you about the policies, procedures and regulations that apply to your COPS MORE 2000 grant. You will be responsible for the information and rules contained in this Manual. More detailed guidance

can be requested through your Grant Program Specialist.

Action: Please read the entire COPS MORE 2000 Grant Owner's Manual carefully

prior to signing the grant Award Page. If you have any questions, please contact your

Grant Program Specialist to discuss them. When you sign the Award Page, you should

ensure that the proper reporting and financial systems are in place to satisfy the

requirements.

12. Equal Employment Opportunity Plan (EEOP)

For grants of $500,000 or more (or $1,000,000 or more in grants over an

eighteen-month period), the grantee acknowledges that failure to submit

an acceptable Equal Employment Opportunity Plan (if grantee is required

to submit one under C.F.R. 42.302) that is approved by the Office of Justice

Programs, Office of Civil Rights, is a violation of its assurances and may

result in the suspension of the drawdown of funds. For grants under

$500,000, the grantee must submit a completed EEOP Certification form

and return it to the Office of Justice Programs, Office of Civil Rights, within 120 days of the grant award
11

Grant Acceptance, Terms, and Conditions

Rationale: The purpose of an Equal Employment Opportunity Plan (EEOP) is to

ensure full and equal participation of men and women regardless of race or national

origin in the workforce of the recipient agency. EEOPs do not impose quotas or hiring requirements. The U.S. Department of Justice (DOJ) regulations regarding the

requirements for an EEOP for Federal grant recipients and the required contents of

the document are fully explained in 28 C.F.R.§ 42.301 et seq.

Action: U.S. DOJ regulations require you to prepare and maintain an EEOP if your

organization:

• Has 50 or more employees; and

• Received a total of $25,000 or more in grants or subgrants; and

• Has 3 percent or more minorities in its service population. Even if there is

less than 3 percent minorities in the service population, the DOJ regulations

require that the EEOP be written to focus on women.

If you meet the above criteria and receive over $500,000 (or a total of $1 million in

grant funds during an 18-month period), you are required to submit an EEOP to:

Office of Civil Rights

Office of Justice Programs

810 7th Street, NW

Washington, D.C. 20531

If you meet the above criteria, but your grant is for under $500,000, or you have

received less than $1 million in grant funds during an 18-month period, you need to

complete and return the one-page COPS EEOP Certification form within 120 days of

your grant award to advise us whether you have an EEOP in effect or whether you are

exempt from this requirement. If you need help preparing an EEOP, please consult

the Seven Step Guide to Preparing an EEOP previously mailed to you or included in

this mailing.

13. Employment Eligibility

The grantee agrees to complete and keep on file, as appropriate, an

Immigration and Naturalization Service Employment Eligibility Verification

Form (I-9). The form is to be used by recipients of Federal funds to verify that persons are eligible to work in the United States.

Rationale: Under Federal immigration law, all employers are required to take certain steps to ensure that persons that are hired are legally permitted to work in the

United States. The Immigration and Naturalization Service Employment Eligibility

Verification Form (I-9) outlines the types of documents that an employer should

review to confirm that a new hire is eligible to be employed. The provisions of this

law apply to employers regardless of whether or not they receive Federal grant funding.
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COPS MORE 2000 Grant Owner’s Manual

Action: You do not need to submit any documentation to the COPS Office to satisfy

this condition. Rather, you should complete and maintain the I-9 forms for all new

employees under the guidelines set forth by the Immigration and Naturalization

Service. For information about this requirement, you may call 202-514-4316 or your

local INS office.

How to Accept the Award

After you have reviewed the conditions of the award and your agency agrees with those

conditions, you are ready to accept the award. At the bottom of the Award Page are

two signature lines. The Director of the COPS Office has signed the Award Page indicating approval of your grant, obligation of Federal funds to your organization and our

commitment to the award. To officially begin the grant and to be able to draw down

your funds, your authorized officials (the law enforcement and government executives) must sign the Award Page and return the original copy to: 

COPS MORE 2000 Control Desk

Office of Community Oriented Policing Services (COPS)

1100 Vermont Avenue NW, 7th Floor

Washington, DC 20530 

(For overnight delivery, please use 20005 as the zip code)

Faxed copies cannot be accepted.

Who should sign the award for my agency?

The "authorized officials" are the individuals in the law enforcement and governmental organizations accepting this grant who have final responsibility for all programmatic and financial decisions of the organizations. In some jurisdictions, police

chiefs and sheriffs have the authority to accept grant awards. In others, the government representative, mayor or county executive may have this authority. However,

COPS grants require that both the law enforcement and government officials with such

authority sign the Award Page. Before signing the grant, you should determine which

individuals in your jurisdiction have the legal authority to accept the award. If you

have any questions as to who should sign the award, please contact your city or county's legal advisor.

When do the grant materials need to be returned?

Please return the signed Award Page within 90 days of your receipt of it. No funds

may be released until we have received your signed Award Page, your budget has

received final clearance, and any other relevant grant conditions particular to your

agency have been satisfied. If you require an extension for accepting the award

beyond the 90-day time frame for any reason, please submit a written request to your

Grant Program Specialist.
13

Grant Acceptance, Terms, and Conditions

What are the specific rules regarding termination of grant funding?

The COPS Office has the right to sanction or to terminate your grant funding when you:

• Are not substantially complying with the requirements of the Public Safety 

Partnership and Community Policing Act, COPS guidelines, or with other 

provisions of Federal law;

• Are failing to make satisfactory progress toward the goals or strategies in

your application, as reflected by performance and status reports;

• Do not adhere to grant agreement requirements or conditions;

• Propose substantial plan changes to the extent that, if originally submitted,

would have resulted in the application not being selected for funding;

• Do not submit reports in a timely manner;

• File false certification in connection with an application, periodic report or

other document submitted to the COPS Office or to COPS Accounting

Operations; and/or

• Provide other good cause for termination.

In these instances, we may:

• Temporarily withhold payments pending correction of the situation by you;

• Disallow all or part of the cost of the activity or action not in compliance;

• Wholly or partly suspend or terminate your grant;

• Require that some or all of the grant amounts be remitted to the U.S. 

Department of Justice;

• Condition a future grant or elect not to provide future grant funds to you

until appropriate actions are taken to ensure compliance;

• Withhold further awards for the program;

• Recommend civil or criminal enforcement by other agencies; and

• Take other remedies that are legally available.

In the event that sanctions are imposed or a grant is terminated, you will be notified

in writing of our decision, and the reason(s) for that decision.

Changes in Your Grant

You must also receive prior written approval if you plan to make the following grant

changes:

• Major programmatic changes (including changes in your required level of 

redeployment);

• Significant changes in your community policing plan;

• Salary and benefit changes; and

• Major budget changes (for example, if your department was awarded dispatchers, but wishes instead to hire administrative assistants) greater than 

$1,000.
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COPS MORE 2000 Grant Owner’s Manual

In order to make one of these changes, you will need to submit your plans in writing

to the COPS Office for prior approval. Please document your reasons for the proposed

changes and add any other information that will assist us in reviewing the changes.

Renewing/Extending Your Grant

If sufficient appropriations are received, funding for civilians may be renewed for up

to two additional years, contingent on a demonstration of how COPS MORE 2000

funds have resulted in the required increase in the number of officers deployed into

community policing. Renewal funding may not exceed the amount of the original

award for civilians. Each renewal period runs exactly one year, with the first renewal beginning at the end of the original grant period. To be eligible for a renewal,

grantees must have hired all awarded civilians. If renewal funding is available, the

COPS Office will send information to you regarding the criteria and procedures for

renewal before the end of the initial grant period.

No-cost time extensions will be given, if necessary, to grantees in order to complete

grant requirements and draw down all grant funds. Extensions do not affect the

amount of the grant, only the end date of the grant. If extensions to complete grant

requirements are necessary, they may be requested 90 days before the end of the grant

period. The COPS Office will send information to you regarding the criteria and procedures for an extension before the end of the initial grant period.

Questions About Accepting the Grant

If for any reason you have questions about accepting this grant, please call your Grant

Program Specialist or contact the U.S. Department of Justice Response Center at 1-

800-421-6770. If you have decided not to accept this grant, please send us a letter

advising us of your decision. 

If you are considering not accepting your COPS MORE 2000 grant, we would be happy

to assist you with any questions you may have. 
Accessing Grant Funds

COPS MORE 2000

Grant Owner’s Manual

Section2

Accessing Grant Funds

17

II. Accessing Grant Funds

This section provides information about how you receive funds and gives answers to

payment-related questions. If you are a new COPS Office grantee, you should receive

a packet of financial documents shortly after we receive your signed award document.

This packet will contain all of the information that you need in order to set up your

payment method and a Financial Guide to assist you with financial management and

grant administration. Currently, there are two methods of payment that you can use

to access your grant funds: PAPRS (payment by phone) and LOCES (electronic payment).

The following explanation of payment methods will assist you in determining which

payment method you would like to use in accessing your COPS grant funds.

Payment Methods

There are currently two methods that you may use to access your grant funds:

A. PAPRS (Phone Activated Paperless Request System)

PAPRS enables grantees to use their touch-tone telephone to request funds. Approved

payment requests will be automatically scheduled for payment by the U.S. Treasury.

The system also provides online information to grantees about the status of their

requests.

If you do not have a touch-tone telephone, please contact the U.S. Department of

Justice Response Center at 1-800-421-6770.

How do we set up a PAPRS account?

If you are a new grantee to the COPS Office, you should receive a packet of financial

documents shortly after we receive your signed award document. This packet will

contain all of the information that you need to set up your payment method. You will

receive a PAPRS user's manual under separate cover from the Office of the

Comptroller, Accounting Division. Once you receive your OJP Vendor Number (which

may or may not be the same as your taxpayer identification number) and PIN number, you can follow the directions in the user's manual to access your funds.

B. LOCES (Letter of Credit Electronic Certification System)

For Previously awarded COPS grantees only 

LOCES is a modem communication system that allows recipients of COPS funds to

electronically request payment from any of their grant funds and receive direct

deposit to their bank accounts within 48 hours. You will need a computer with a dedicated modem in order to use this system.

1. To make requests for payments through LOCES, you must have a personal computer operating DOS 3.1 or higher. We recommend at least a 28.8-baud modem.
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COPS MORE 2000 Grant Owner’s Manual

2. Complete and return the LOCES Automation Survey form. Upon receipt, your 

LOCES software will be customized for your use and forwarded to you.

3. Complete an ACH Vendor / Miscellaneous Payment (SF 3881) enrollment form

and forward to your bank.

A complete LOCES form and manual package may be requested by contacting COPS

Accounting Operations at 1-800-421-6770. In addition, Accounting Operations can

provide technical assistance on using the LOCES system.

What are the Benefits of LOCES?

The LOCES method is a completely computerized method of payment. It also allows

you to file your quarterly Financial Status Reports (SF-269) electronically.

Setting up Your Account

How do I fill out the payment enrollment forms?

In the packet of financial documents you received is an Automated Clearing House

(ACH) Vendor / Miscellaneous Payment (SF 3881) enrollment form. The ACH Vendor

/ Miscellaneous Payment (SF 3881) enrollment form needs to be filled out regardless

of the payment method selected. Prior to trying to access your funds, you must fax

this form to:

Office of the Comptroller

Fax: 202-353-9279

Or mail to:

Office of the Comptroller

810 7th Street, 5th Floor

Washington, DC 20531

The "Agency Information" section has been filled out by our Accounting Operations.

Your agency needs to fill out the "Payee / Company Information" section following the

directions on the back of the form. You also need to provide the grant number (printed on the Award Page) on this form. Then you must have your financial institution

complete the "Financial Institution Information" section and have the appropriate

financial official sign the form.

If you are already a COPS Office grantee, you should already have selected one of the

two payment methods and filled out an ACH Vendor / Miscellaneous Payment (SF

3881) enrollment form. If you have any questions, please call COPS Accounting

Operations at 1-800-421-6770.
Accessing Grant Funds

19

Do I need a Financial Status Report to open my account?

As part of Federal auditing requirements, your agency has to complete a Financial

Status Report (Standard Form 269) quarterly. Payment requests will be denied if the

current 269 is overdue. Please make blank copies of the form (both sides) provided in your award packet and retain them for future use. This form is a report of your

expenditures for the grant. The Financial Status Report is due 45 days following the

end of a calendar quarter (calendar quarters end March 31, June 30, September 30,

and December 31). Even when you have not expended any funds during a quarter,

the Financial Status Report should be submitted with zeros in the appropriate spaces.

When setting up your account, check to see when the last quarter ended and fill out

a Financial Status Report to reflect the amount of your agency's expenditures for the

grant during that quarter, and submit the form along with the ACH Vendor form. For

the rest of the year, please submit Financial Status Reports no later than May 15,

August 15, November 15, and February 15.

Completing the Financial Status Report does not mean that you will be reimbursed for

the amount you show as being expended. You must still request payment through

PAPRS or LOCES (see section on payment methods).

For more information, see the section of this Manual entitled "Reports."

Additional Payment Questions

Can we receive advances?

Yes. If you receive funds through electronic transfer, the period allowed is ten (10)

days in advance. 

In general, the concept of "minimum cash on hand" applies to COPS grants. The minimum cash on hand concept requires that you request funds based upon immediate

cash disbursement needs. You should time your request for payment to ensure that

Federal cash on hand is the minimum that you need to make your immediate salary

and fringe benefits payments. There should be no excess Federal grant funds on

hand, except for approved advances discussed above.

The Federal government has four basic rules regarding advances. Advances can be

terminated if the grantee:

• Is unwilling or unable to attain project goals;

• Maintains excess cash on hand;

• Does not adhere to the terms and conditions of the grant; or

• Fails to submit reliable and timely reports.

LOCES allows you to electronically

request and receive grant funds.
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COPS MORE 2000 Grant Owner’s Manual

How often do we request reimbursement of costs?

There are no definitive guidelines on how often you should request reimbursements.

Only reimbursements for actual salaries and benefits of COPS MORE 2000 civilians

can be made.

Can we earn interest on our grant funds?

You should minimize the time between your drawdown of grant funds and your payment of grant costs. You need to account for interest earned on advances of Federal

funds as follows:

• You may keep interest earned on all advances of Federal grant funds 

up to $250 per fiscal year; and

• Annually pay back interest earned (over and above $250 per fiscal 

year) on advances of Federal grant funds to the U.S. Department of 

Health and Human Services, Payment Management Systems, 

Rockville, MD 20852.
Meeting the Local Match

COPS MORE 2000

Grant Owner’s Manual

Section3

Meeting the Local Match

23

III. Meeting the Local Match

The COPS MORE 2000 program provides up to 75 percent of the cost of allowable

items. COPS MORE 2000 grantees are responsible for at least 25 percent of the total

cost of allowable items, unless the requirement of a local cash match has been waived

in whole or in part. Matching contributions may be applied at any time during the life

of your grant provided that the full matching share is obligated by the end of the grant

period.

Payment Sources for Matching Funds

• Program income funds from asset forfeitures;

• Funds from state or local government that are committed to matching funds

for your program;

• Funds from Federal programs which specifically authorize use as matching

funds such as the Housing and Community Development Act of 1974 or the

Equitable Sharing Program; or

• Funds contributed by private sources.

Matching funds may not be taken from funds otherwise budgeted for law enforcement

purposes. In other words, your local match may not be paid through any reallocation of already budgeted law enforcement funds.

Should I maintain records of the match?

You must maintain records of your local share. These records should clearly show the

source of the match, the amount of the match, and when the match was contributed.

Waivers

Can the matching requirement be waived?

In order to maximize the number of communities that can take advantage of COPS

grants, only a very small portion of waiver requests are granted. Waiver requests can

only be considered when a jurisdiction makes the request at the time of grant application. Applicants that are able to provide satisfactory documentation of severe economic distress may be granted waivers. Except in extreme situations, waiver requests

received after an award has been made will not be considered.

How are waivers granted?

It is the burden of the jurisdiction to demonstrate extreme fiscal distress at the time

of application. Waivers fall under two categories: presumptive and case-by-case. If,

at the time of application, the applicant is declared bankrupt by a court of law or

placed in receivership by the state or Federal government, a presumptive waiver is

granted. The following are examples of case-by-case waivers that must be reviewed

by the COPS Office and must demonstrate severe fiscal distress:
24

COPS MORE 2000 Grant Owner’s Manual

Waivers of the local match are

granted only in cases of severe 

fiscal distress.

• Budgetary imbalance or expenditure cutbacks resulting in significant reductions in other services provided by the applicant;

• Significant lay-offs of personnel with the applicant department;

• Significant downgrading of applicant’s bond rating due to fiscal 

stress;

• Location within an area in which a declaration of major disaster has been

made pursuant to the Robert T. Stafford Disaster Relief and Emergency

Assistance Act; or

• Other circumstances demonstrating severe fiscal distress.

How are we notified whether a waiver was granted?

The cover letter and financial clearance memo in your grant award package will indicate whether your request for a waiver was granted. If you received a waiver and have

additional questions, please contact your Grant Program Specialist.

Please note that if you did receive a waiver, you are still required to develop and

implement a plan for the retention of the funded position(s) (and continuation of

time savings and redeployment) with state or local funds following the conclusion of

Federal assistance.

How do we appeal the denial of a waiver?

If your waiver request was denied and you would like to appeal the decision, please

make your appeal to:

U.S. Department of Justice

Office of Community Oriented Policing Services (COPS)

Attn: Waiver Team 

1100 Vermont Avenue, NW

Washington, D.C. 20530

(For overnight delivery, please use 20005 as the zip code)
Financial Record Maintenance

COPS MORE 2000

Grant Owner’s Manual

Section4

27

Financial Record Maintenance

IV. Financial Record Maintenance

Under your COPS MORE 2000 grant, you are required to establish and maintain

accounting systems and financial records to accurately account for funds awarded

and disbursed. These records need to include both Federal funds and all matching

funds from state, local and private organizations. 

Accounting Systems

What accounting systems are needed?

You need to establish and maintain accounting systems and financial records to accurately account for funds awarded to you. These records should include both Federal

funds and matching funds of state, local, and private organizations.

Your accounting system should:

• Present and itemize approved costs of salaries and benefits;

• Assure responsible use of grant funds;

• Assure that all expenditures of funds are in conformance with your grant 

conditions; and 

• Be able to provide the necessary information for periodic financial review 

and audit.

What records should be kept?

Your fiscal control and accounting systems should enable you to make accurate, current and complete disclosure of the financial activity under your COPS MORE 2000

grant. Your accounting records should contain information showing expenditures

under the grant, and must be supported by items such as payroll, time and attendance

records, canceled checks, or similar documents.

You must adequately safeguard grant funds and make sure that they are used for

authorized purposes. You will be responsible for refunding expenditures disallowed

by auditors.

How long should documents be kept?

All financial records, including payroll, time and attendance records, canceled checks

and similar documents associated with your COPS MORE 2000 grant should be kept

for at least three years from the grant closing date. If any litigation, claim, negotiation, audit or other action involving these records has been started before the end of

the three-year period, the records should be kept until completion of the action.

These records should be easily located and should be properly protected against fire

or other damage.
28

COPS MORE 2000 Grant Owner’s Manual

Records should be kept for at least

three years from the grant closing

audit report date.

You should maintain your records so that you can identify them by grant year or by

your fiscal year, whichever you find more convenient.

What if we have more than one grant?

If you have more than one Federal grant, funds received under one project may not

be used to support another project without specific written authorization from the

awarding agency. Your accounting systems and financial records must reflect expenditures for each project separately.

Who may access our records?

Authorized Federal representatives, including the representatives of the U.S.

Department of Justice and the Comptroller General for the United States, may access

these records as long as they exist for the purposes of making audits, examinations,

excerpts or transcripts.
Federal Audit Requirements

COPS MORE 2000

Grant Owner’s Manual

Section5

Federal Audit Requirements

31

V. Federal Audit Requirements

Audit Requirements

In addition to oversight, guidance and counsel provided by the COPS Office, your

grant may be subject to an audit by independent examiners. The two primary types

of audits are Single Audit Act (SAA) audits and Department of Justice (DOJ), Office of

Inspector General (OIG) audits. These audits are designed to determine whether you

have systems in place, controls established, and reports providing reasonable assurance that your organization is managing the COPS MORE 2000 funds in compliance

with laws, regulations, and provisions specified in this manual. Failure to comply with

audit requirements may result in adverse current and future funding determinations.

COPS established the Compliance Staff, under the direction of a Program Compliance

Officer, in Fiscal Year 2000 to serve as the liaison between grantees and auditors in

the conduct of audits. The Compliance Staff’s liaison responsibilities include, but are

not limited to, addressing grantee inquiries regarding audit processes; providing

grantees with technical assistance in responding to audit reports; evaluating the accuracy of identified findings (problem areas) and recommendations to correct problem

areas; facilitating closure on audit findings and recommendations; and tracking current, pending, and completed audit initiatives. The Compliance Staff may be contacted by telephone through the Department of Justice Response Center at (800) 421-

6770. Compliance Staff members and the Program Compliance Officer are available

to address questions and provide assistance regarding the SAA and OIG audit processes. Questions and comments regarding the administration of your grant(s), not

specifically related to an audit, should be referred to your Grant Program Specialist.

Who must have an audit?

Audit requirements: State and local governments, nonprofit organizations, and institutions of higher education receiving Federal funds are governed by OMB Circular A133. Whether an audit is required under this circular is dependent upon the amount

of Federal funds expended during the recipient's fiscal year. If the organization

expends $300,000 or more per year in Federal funds, the organization must have an

audit conducted in accordance with OMB Circular A-133 audit requirements.

State and local governments, nonprofit organizations, and institutions of higher education expending less than $300,000 a year in Federal awards are exempt from

Federal audit requirements, but records must be available for review by appropriate

officials of the Federal grantor agency or subgranting entity. 

Single Audit Act Audits

What is a Single Audit Act audit?

An SAA audit is an examination of a non-Federal entity's financial statements and

Federal awards by public accountants or Federal, state or local government audit

organizations. The purpose of the SAA is to determine: 1) whether financial state-
32

COPS MORE 2000 Grant Owner’s Manual

ments are presented fairly, in conformity with generally accepted accounting principles; 2) whether the schedule of expenditures of Federal awards is presented fairly in

relation to the financial statements taken as a whole; 3) if internal controls are sufficient to minimize risk; and 4) compliance with laws, regulations, and grant provisions

having a material effect on major programs.

What are the regulations governing SAA requirements?

The Single Audit Act was created in 1984, which established uniform guidelines for

state and local governments receiving Federal financial assistance. The 1984 Act was

amended in July 1996 to reflect revised audit criteria and reporting requirements.

The Office of Management and Budget Circular A-133, Audits of States, Local

Governments, and Non-Profit Organizations, provides additional guidelines regarding

the implementation of SAA requirements.

Who must have an SAA audit?

Each non-Federal entity that expends a total amount of Federal awards equal to or in

excess of $300,000 in a fiscal year shall have an SAA audit for that fiscal year.

A non-Federal entity that expends Federal awards under more than one Federal program shall undergo an SAA audit encompassing all operations; or, at the option of the

non-Federal entity, the SAA audit may include a series of audits encompassing the

organizational units which expended or administered grants during the fiscal year. If

the latter alternative is selected, the SAA audit must include the financial statements

and schedule of expenditures of Federal awards for each organizational unit encompassed in the audit.

When an entity expends Federal awards under only one Federal program and the

Federal program's laws, regulations, and grant provisions do not require a financial

statement for the Federal program, your organization may elect to have a programspecific audit conducted. Unlike an SAA audit, encompassing all of the entity's operations, the scope of a program-specific audit includes the financial, internal control,

and compliance issues governing the program under review.

How frequently are SAA audits conducted?

SAA audits are conducted annually unless a state or local government is required by

constitution or statute, in effect on January 1, 1987, to undergo audits less frequently than annually. If such constitution or statute does exist, the entity is permitted to

undergo an audit biennially. Non-profit organizations that had biennial audits for all

biennial periods ending between July 1, 1992 and January 1, 1995, are permitted to

undergo biennial audits. All biennial audits must cover both years within the biennial period.

What are the primary steps included in the SAA audit process?

The auditor retained by your organization will conduct testing to determine whether

the financial statement and schedule of expenditures of Federal awards are presented fairly, in all material respects. The auditor will also conduct internal control and
Federal Audit Requirements

33

compliance testing to determine adherence to laws, regulations, and grant provisions

as well as adequate protection of resources from fraud, waste, and abuse. Once testing is completed, the auditor will issue a report reflecting the results of financial statement, internal control, and compliance testing, which includes findings and recommendations for areas deemed non-compliant and/or vulnerable. Upon receiving the

auditor's report, your organization will prepare a corrective action plan for each finding and recommendation. The corrective action plan reflects agreement or disagreement with the findings and recommendations, information to support a position of

disagreement, and both completed and anticipated actions to address the findings and

recommendations.

You must submit the auditor's report and corrective action plan to the Federal

Clearinghouse within the earlier of 30 days after receiving the auditor's report or nine

months after the end of the audit period. The Federal Clearinghouse is a central

repository for all SAA audits and is responsible for tracking the submission of SAA

reports and distributing SAA reports to appropriate parties. If the report contains

findings and recommendations applicable to DOJ operations, the Federal

Clearinghouse distributes the reporting package to DOJ's Office of Inspector General

(OIG). OIG evaluates the audit findings and recommendations and distributes the

report to DOJ's Office of Justice Programs for audit follow-up. If an audit discloses

findings and recommendations directly related to the administration of COPS grants,

OJP provides COPS' Compliance Staff with a copy of the audit report to facilitate resolution and closure. Serving in this capacity, COPS' Compliance Staff serves as the liaison among the SAA auditor, OIG, OJP, and your office and provides technical assistance with respect to audit follow-up initiatives, including requests for updated corrective action plans. Questions and comments regarding the administration of your

grant(s), unrelated to an OIG or SAA audit, should be referred to your Grant Program

Specialist, rather than the Compliance Staff.

Office of The Inspector General Audits

What is the role of the Office of the Inspector General?

The OIG is an independent agency within DOJ authorized to conduct audits related to

DOJ program, financial, and administrative operations. OIG audits are designed to

promote economy, efficiency, and effectiveness in the administration of grants by evaluating compliance with laws, regulations, and policies and procedures governing the

operations encompassed in the scope of the audit.

On what basis are COPS grants selected for an OIG audit?

Occasionally, the OIG conducts a COPS grant audit in response to a referral that the

OIG believes warrants further evaluation. The OIG also surveys DOJ agencies on an

annual basis to solicit input on suggested audit areas for the upcoming fiscal year. In

most instances, however, the OIG selects grants taking into consideration many factors including, but not limited to, geographical distribution of grants awarded, award

amount, population served, and type of grant. As such, the fact that your grant has

been selected for an OIG audit is not necessarily indicative of a suspected concern or

problem area; but, instead, is typically part of the overall selection process
34

COPS MORE 2000 Grant Owner’s Manual

What is encompassed in the scope of an OIG audit?

Typically, OIG audits encompass all COPS grants awarded to your agency, both active

and expired. The OIG conducts testing to determine compliance with program,

administrative, and financial requirements for each of the grants selected.

Compliance areas may include, but not be limited to, supplanting, retention, allowable costs, local match, redeployment, financial and programmatic reporting, and

community policing grant provisions. Once testing is completed, The OIG issues a

report which includes an analysis of areas deemed non-compliant, as well as recommendations to correct problem areas. The OIG's recommendations may include

returning a portion or all of your grant funding. As such, it is imperative that you

remain aware of and comply with grant provisions, implement effective accounting

systems, and maintain detailed, accurate records supporting the administration of

your grant(s).

How will I be notified of an upcoming OIG audit? What will I need to

do to prepare?

Typically, the OIG will notify COPS of upcoming audits, at which time COPS will send

you a notification letter indicating a COPS point of contact to address your questions

and comments, as well as a description of information/documentation that will need

to be made available to the OIG during their scheduled on-site visit. If the OIG notifies you of their upcoming audit prior to notification from the COPS Office, please feel

free to call the COPS Compliance Staff to discuss questions and comments regarding

the audit process. 

After COPS issues a notification letter to your organization, the OIG will issue a similar letter specifying the information that will be needed and scheduled date for the

introductory entrance conference. At this point, you will work with both the OIG and

COPS to further the audit process.

What are the primary steps included in the OIG audit process?

After an entrance conference is conducted between your organization and the OIG,

the auditors will conduct analysis and inquiries regarding the administration of your

grant(s). Based on the information/documentation obtained in response to inquiries,

the OIG may identify potential or actual vulnerabilities and/or areas deemed noncompliant with grant provisions, which collectively are referred to as "findings." The

OIG will state their findings and recommendations in a draft audit report, which will

be furnished to your office and the COPS Office for review and comment. The

response to the draft audit report provides you and COPS an opportunity to indicate

concurrence or nonconcurrence with the OIG's findings and recommendations and

what, if any, action has been or will be taken to address the findings and recommendations. Upon receiving your response and COPS' response to the draft audit report,

the OIG will issue a final report identifying whether each recommendation is "open,"

meaning additional action is needed to address the finding and recommendation, or

"closed," meaning all actions necessary to address the finding and recommendation

have been fully implemented.
35

Federal Audit Requirements

After the final report has been issued, the COPS Compliance Staff will continue working as the liaison between your office and the OIG to close the open audit findings and

recommendations. Serving in this capacity, COPS will advise you as to what information/documentation is needed to attain closure on the open audit recommendations,

evaluate your information for accuracy and completeness, and furnish the information to the OIG to facilitate closure. This process continues until all audit recommendations are closed, at which time you will be issued a letter confirming closure of

the entire audit. You must keep all documentation related to the audit for a period of

three years after the audit closure date. If an investigation or official inquiry occurs

either during the audit period or within three years of the audit closure date, you must

keep all audit records until the investigation or inquiry has been completed.

Reports

COPS MORE 2000

Grant Owner’s Manual

Section6

39

Reports

VI. Reports

Periodically, you will be asked to respond to three types of reports: 1) Program

Progress Reports; 2) Quarterly Financial Status Reports; and 3) telephone surveys

about redeployment. In addition, a baseline survey of current community policing

activities and levels of redeployment in community policing will be conducted at the

beginning of the grant period, through the Community Policing Information

Worksheet. Funds and future awards may be withheld if reports are not returned or

are excessively late.

Program Progress Reports

How often will progress reports be requested?

Program progress reports will be requested at least once during the grant period.

What kind of information will be requested?

These reports will request information about the increased levels of community policing that have resulted from funding under COPS MORE 2000. The information

requested will include documentation that demonstrates that the required level of

redeployment is being monitored and maintained. 

How and when will these forms be sent?

These reports and instructions will be mailed to you during the course of your grant

period. You will also receive periodic phone calls from your Grant Program Specialist

regarding the status of your grant. In addition, a COPS Office representative may also

make a site visit to your agency during the grant period.

Financial Status Reports

How will grant funds be monitored?

COPS Accounting Operations monitors the financial aspects of your grant through

financial reports, meetings, telephone contacts, reports, audits, reviews of grant

change requests and special request submissions. In specific cases, information may

be requested during an on-site visit.

How do I file Financial Status Reports under PAPRS?

Under the COPS PAPRS system, you are required to complete and return quarterly

Financial Status Reports (SF-269) within 45 days after the end of the calendar quarter. The Financial Status Reports request information on your monies spent, including amounts for Federal expenditures, local matching contributions, and the unobligated balance of the award. Please make blank copies of the form (both sides) provided in your award package and retain them for future use.
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COPS MORE 2000 Grant Owner’s Manual

You will be unable to access funds in the PAPRS system if you have not submitted these Financial Status Reports or your signed Award Page.

How do I file Financial Status Reports under LOCES?

Under the LOCES payment method, you are required to complete and return quarterly Financial Status Reports (SF-269) within 45 days after the end of the calendar quarter. You have the option of completing those reports electronically.

Cash Reconciliation Reports

COPS Accounting Operations will send you a Cash Reconciliation report on a semiannual basis. This report includes all cash activity related to your award during the period. You will need to verify the accuracy of that report. No response is necessary if

the information reflected in the report is in agreement with your records. If the information differs from your records, please notify COPS Accounting Operations in writing outlining the identified differences. 

Telephone Calls About Redeployment

How often will calls be made? 

The COPS Office will contact your agency periodically, up to two times a year, to determine your grant progress and the number of officers redeployed to community policing to date.

What will be asked during the telephone contact?

The COPS Office will ask for the number of officers redeployed, and a timetable for

when future redeployment may occur, if it has not occurred already.

How to Report Violations (Fraud, Waste, and Abuse)

Any alleged violations, serious irregularities, or acts that may result in the use of public funds in a manner inconsistent with the Public Safety Partnership and Community

Policing Act of 1994 or the purposes of this grant, please report such to the U.S.

Department of Justice Inspector General Hotline at 1-800-869-4499. We would greatly appreciate your cooperation to help us ensure that these Federal grant funds are

spent responsibly.
When the Grant Period Ends

COPS MORE 2000

Grant Owner’s Manual

Section7

43

When the Grant Period Ends

VII. When the Grant Period Ends

Grant “Close Out”

At the end of your grant period, the COPS Office is responsible for the "close out" of

your grant. To fulfill this requirement, we must determine that you, as well as the

COPS Office, have completed all of the work required by the grant.

Within 90 days of the end of the grant period, you will be asked to submit final financial and program reports. These reports will be very similar to the reports discussed

in Section VI.

Final Financial Status Report

The final Financial Status Report of your grant expenditures is due within 120 days

after the end of the grant period. [Example: If the award period is 6/1/2000 to

5/31/2001, the final report is due by 9/30/2001.] This final report should reflect the

total amount of Federal expenditures, the total amount of matching contributions, and

the amount of unobligated funds, if any. Any unobligated or unspent funds will be

deobligated from the award amount.

When should all of the grant monies be spent?

Grant funds must be obligated by the end of the grant period. Obligated funds cover

expenses that you have incurred but not yet paid. You have 120 days after the end of

the grant period to expend grant funds that have been obligated. Any grant funds that

you do not request payment for at the end of the 120 days will revert to the COPS

Office.

Final Progress Report

Within 120 days of the end of your grant award period, the COPS Office will ask you

to submit a final program progress report. The final progress report with instructions

will be mailed to you, and will request information similar to previous program

progress reports.
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COPS MORE 2000 Grant Owner’s Manual

Conclusion

We hope that this Manual has assisted you with your grant questions. We welcome

and encourage any comments you have regarding COPS MORE 2000 and the materials that we have developed for its administration. If you have specific comments

regarding this Manual, please send them to:

COPS MORE 2000 GRANT OWNER'S MANUAL

1100 Vermont Avenue NW, 7th Floor

Washington, DC 20530

(For overnight delivery, please use 20005 as the zip code.)

We will review these comments and make revisions as appropriate.

If you have any questions about your grant, please call the Department of Justice

Response Center at 1-800-421-6770 or your Grant Program Specialist.
Appendices

COPS MORE 2000

Grant Owner’s Manual

Section8

47

Appendices

Appendix A

List of Source Documents

Primary Sources:

Public Safety Partnership and Community Policing Act of 1994, 42 U.S.C.

U.S. Department of Justice, Office of Justice Programs, Financial and Administrative

Guide for Grants, OJP M 7100.1D: May 15, 1990

Additional Sources:

Code of Federal Regulations (CFR)

28 CFR Part 66 Uniform Administrative Requirements for Grants and Cooperative

Agreements to State and Local Governments

28 CFR Part 67 Government wide Requirements for Drug-Free 

Workplaces (Grants)

28 CFR Part 69 Government wide New Restrictions on Lobbying

31 CFR Part 205 Treasury Department Regulations Implementing for Cash 

Management Improvement Act of 1990

OMB Circular A-87 Cost Principles for State and Local Governments

OMB Circular A-33 Audits of Educational Institutions

Assurances for Universal Hiring (Included)

Executive Order 12547 "Non-Procurement Debarments and Suspension"

Executive Order 12372, 28 CFR, Part 30 "Intergovernmental Review of Federal

Programs"

OMB Circular A-129 Managing Federal Credit Programs

4 CFR Parts 101-105 Department of Justice/General Accounting Office, "Joint Federal

Claims Collections Standards"

5 CFR Part 1320 "Controlling the Paperwork Burden on the Public"

Executive Order 12291 "Regulations"

5 CFR Part 151 "Political Activities of State and Local Officials or Employees"
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COPS MORE 2000 Grant Owner’s Manual

Appendix B - Assurances

1. You have been legally and officially authorized by the appropriate governing body (for example, mayor or city council) to apply for this grant

and that the persons signing the application and these assurances on your

behalf are authorized to do so and to act on your behalf with respect to

any issues that may arise during processing of this application.

2. You will comply with the provisions of Federal law which limit certain

political activities of your employees whose principal employment is in

connection with an activity financed in whole or in part with this grant.

These restrictions are set forth in 5 U.S.C. § 1501, et seq.

3. You will comply with the minimum wage and maximum hours provisions of the Federal Fair Labor Standards Act, if they apply to you.

4. You will establish safeguards, if you have not done so already, to prohibit employees from using their positions for a purpose that is, or gives

the appearance of being, motivated by a desire for private gain for themselves or others, particularly those with whom they have family, business

or other ties.

5. You will give the Department of Justice or the Comptroller General

access to and the right to examine records and documents related to the

grant.

6. You will comply with all requirements imposed by the Department of

Justice as a condition or administrative requirement of the grant; with the

program guidelines; with the requirements of OMB Circulars A-87 (governing cost calculations) and A-128 or A-133 (governing audits); with the

applicable provisions of the Omnibus Crime Control and Safe Streets Act

of 1968, as amended; with 28 CFR Part 66 (Uniform Administrative

Requirements); with the provisions of the current edition of the appropriate COPS grant owner’s manual; and with all other applicable laws,

orders, regulations or circulars.

7. You will, to the extent practicable and consistent with applicable law,

seek, recruit and hire qualified members of racial and ethnic minority

groups and qualified women in order to further effective law enforcement

by increasing their ranks within the sworn positions in your agency.

8. You will not, on the ground of race, color, religion, national origin,

gender, disability or age, unlawfully exclude any person from participation in, deny the benefits of or employment to any person, or subject any

person to discrimination in connection with any programs or activities

funded in whole or in part with Federal funds. These civil rights requirements are found in the non-discrimination provisions of the Omnibus

Crime Control and Safe Streets Act of 1968, as amended (42 U.S.C. §

3789(d)); Title VI of the Civil Rights Act of 1964, as amended (42 U.S.C.

§ 2000d); the Indian Civil Rights Act (25 U.S.C. §§ 1301-1303); Section

504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794); Title

II, Subtitle A of the Americans with Disabilities Act (ADA) (42 U.S.C. §

12101, et seq.); the Age Discrimination Act of 1975 (42 U.S.C. § 6101, et

seq.); and Department of Justice Non-Discrimination Regulations contained in Title 28, Parts 35 and 42 (subparts C, D, E and G) of the Code

of Federal Regulations.

A. In the event that any court or administrative agency makes a finding of

discrimination on grounds of race, color, religion, national origin, gender, disability or age against you after a due process hearing, you agree to

forward a copy of the finding to the Office of Civil Rights, Office of Justice

Programs, 810 7th Street, NW, Washington, DC 20531.

B. If you are applying for a grant of $500,000 or more and Department

regulations (28 CFR 42.301 et seq.) require you to submit an Equal

Opportunity Employment Plan, you will do so at the time of this application, if you have not done so in the past. If you are applying for a grant of

less than $500,000 and the regulations require you to maintain a Plan on

file in your office, you will do so within 120 days of your grant award.

9. You will insure that the facilities under your ownership, lease or

supervision which shall be utilized in the accomplishment of the project

are not listed on the Environmental Protection Agency’s (EPA) list of

Violating Facilities and that you will notify us if you are advised by the EPA

indicating that a facility to be used in this grant is under consideration for

listing by EPA.

10. If your state has established a review and comment procedure under

Executive Order 12372 and has selected this program for review, you

have made this application available for review by the state Single Point of

Contact.

11. You will devise a plan to retain the increased hiring level with state

and local funds after the conclusion of your grant.

Several provisions of Federal law and policy apply to all grant programs. We (the Office of Community Oriented Policing Services) need to secure your assurance that you (the applicant) will comply with these provisions. If you would like further information about any of the matters on which we seek your assurance, please contact us.

By your authorized representative’s signature, you assure us and certify to us that you will comply with all legal and administrative requirements that govern the applicant for acceptance and use of Federal grant funds. In particular, you assure us that:

I hereby certify compliance with the above assurances that govern the application and use of Federal funds.

Signature: ________________________________________________________________ Date: ______________________
49

Appendices

Certifications

Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; Drug-Free Workplace Requirements Coordination

with Affected Agencies; Non-Supplanting; and Retention.

Although the Department of Justice has made every effort to simplify the application process, other provisions of Federal law require us to seek your certification regarding certain matters. Applicants should read the regulations cited below and the instructions for certification included in the regulations to understand the requirements and whether they apply to a particular applicant. Signature of this form provides for compliance with certification requirements under

28 CFR Part 69, "New Restrictions on Lobbying," and 28 CFR Part 67, "Government-wide Debarment and Suspension (Nonprocurement) and Government-wide

Requirements for Drug-Free Workplace (Grants)," and the coordination and non-supplanting requirements of the Public Safety Partnership and Community

Policing Act of 1994. The certifications shall be treated as a material representation of fact upon which reliance will be placed when the Department of Justice

determines to award the covered grant.

1. Lobbying

As required by Section 1352, Title 31 of the U.S. Code, and implemented

at 28 CFR Part 69, for persons entering into a grant or cooperative agreement over $100,000, as defined at 28 CFR Part 69, the applicant certifies

that:

A. No Federal appropriated funds have been paid or will be paid,

by or on behalf of the undersigned, to any person for influencing or

attempting to influence an officer or employee of any agency, a

Member of Congress, an officer or employee of Congress, or an

employee of a Member of Congress in connection with the making

of any Federal grant; the entering into of any cooperative agreement; and the extension, continuation, renewal, amendment or

modification of any Federal grant or cooperative agreement;

B. If any funds other than Federal appropriated funds have been

paid or will be paid to any person for influencing or attempting to

influence an officer or employee of any agency, a Member of

Congress, an officer or employee of Congress, or an employee of a

Member of Congress in connection with this Federal grant or cooperative agreement, the undersigned shall complete and submit

Standard Form — LLL, "Disclosure of Lobbying Activities," in

accordance with its instructions;

C. The undersigned shall require that the language of this certification be included in the award documents for all subawards at all

tiers (including subgrants, contracts under grants and cooperative

agreements, and subcontracts) and that all sub-recipients shall certify and disclose accordingly. 

2. Debarment, Suspension and Other Responsibility Matters 

(Direct Recipient)

As required by Executive Order 12549, Debarment and Suspension, and

implemented at 28 CFR Part 67, for prospective participants in primary

covered transactions, as defined at 28 CFR Part 67, Section 67.510 — 

A. The applicant certifies that it and its principals: 

(i) Are not presently debarred, suspended, proposed for debarment,

declared ineligible, sentenced to a denial of Federal benefits by a state or

Federal court, or voluntarily excluded from covered transactions by any

Federal department or agency;

(ii) Have not within a three-year period preceding this application been

convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing public (Federal, state or local) transaction

or contract under a public transaction; violation of Federal or state

antitrust statutes or commission of embezzlement, theft, forgery, bribery,

falsification or destruction of records, making false statements, or receiving stolen property;

(iii) Are not presently indicted for or otherwise criminally or civilly

charged by a governmental entity (Federal, state or local) with commission of any of the offenses enumerated in paragraph (A)(ii) of this certification; and

(iv) Have not within a three-year period preceding this application had

one or more public transactions (Federal, state or local) terminated for

cause or default; and

B. Where the applicant is unable to certify to any of the statements in this

certification, he or she shall attach an explanation to this application.

3. Workplace (Grantees Other Than Individuals)

As required by the Drug-Free Workplace Act of 1988, and implemented

at 28 CFR Part 67, Subpart F, for grantees, as defined at 28 CFR Part 67,

Sections 67.615 and 67.620 — 

A. The applicant certifies that it will, or will continue to, provide a drugfree workplace by:

(i) Publishing a statement notifying employees that the unlawful

manufacture, distribution, dispensing, possession or use of a controlled

substance is prohibited in the grantee's workplace and specifying the

actions that will be taken against employees for violation of such prohibition;

(ii) Establishing an on-going drug-free awareness program to

inform employees about — 

(a) The dangers of drug abuse in the workplace;

(b) The grantee's policy of maintaining a drug-free workplace;

(c) Any available drug counseling, rehabilitation and employee

assistance programs; and

(d) The penalties that may be imposed upon employees for drug-abuse

violations occurring in the workplace;
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COPS MORE 2000 Grant Owner’s Manual

(iii) Making it a requirement that each employee to be engaged in the

performance of the grant be given a copy of the statement required by

paragraph (i);

(iv) Notifying the employee in the statement required by paragraph (i)

that, as a condition of employment under the grant, the employee will — 

(a) Abide by the terms of the statement; and

(b) Notify the employer in writing of his or her conviction for a violation

of a criminal drug statute occurring in the workplace no later than five

calendar days after such conviction;

(v) Notifying the agency, in writing, within 10 calendar days after receiving notice under subparagraph (iv)(b) from an employee or otherwise

receiving actual notice of such conviction. Employers of convicted

employees must provide notice, including position title, to: COPS Office,

1100 Vermont Ave., NW, Washington, DC 20530. Notice shall include the

identification number(s) of each affected grant;

(vi) Taking one of the following actions, within 30 calendar days of

receiving notice under subparagraph (iv)(b), with respect to any employee who is so convicted — 

(a) Taking appropriate personnel action against such an employee, up

to and including termination, consistent with the requirements of the

Rehabilitation Act of 1973, as amended; or

(b) Requiring such employee to participate satisfactorily in a drug abuse

assistance or rehabilitation program approved for such purposes by a

Federal, state or local health, law enforcement or other appropriate

agency;

(vii) Making a good faith effort to continue to maintain a drug-free workplace through implementation of paragraphs (i), (ii), (iii), (iv), (v) and

(vi).

B. The grantee may insert in the space provided below the site(s) for the

performance of work done in connection with the specific grant: 

Place of performance (street address, city, county, state, zip code)

__________________________________________________

________________________________

Check  if there are workplaces on file that are not identified here. 

Section 67.630 of the regulations provides that a grantee that is a state

may elect to make one certification in each Federal fiscal year, a copy of

which should be included with each application for Department of Justice

funding. States and state agencies may elect to use OJP Form 4061/7.

Check  if the state has elected to complete OJP Form 4061/7.

4. Coordination

The Public Safety Partnership and Community Policing Act of 1994

requires applicants to certify that there has been appropriate coordination with all agencies that may be affected by the applicant's grant proposal if approved. Affected agencies may include, among others, the

Office of the United States Attorney, state or local prosecutors, or correctional agencies. The applicant certifies that there has been appropriate

coordination with all affected agencies. 

5. Non-Supplanting

The applicant hereby certifies that Federal funds will not be used to

replace or supplant state or local funds, or funds supplied by the Bureau

of Indian Affairs, that would, in the absence of Federal aid, be made available to or for law enforcement purposes.

6. Retention

The applicant hereby certifies that it understands that it must abide by its

submitted plan to retain the additional civilian positions and redeployment levels at the conclusion of the grant period.

Grantee Name and Address:

____________________________________________________________________________________

Application No. and/or Project Name: ______________________________ Grantee IRS/ Vendor Number: ____________

Typed Name and Title of Law Enforcement Representative: __________________________________________________

Signature: __________________________________________________________ Date: ____________________

As the duly authorized representative of the governing body, I hereby certify that the I am binding the governing body to the

above certifications, including the plan to retain. Elections of new officials will not relieve the governing body of its obligations under this grant.

Typed Name and Title of Government Representative: ____________________________________________________

Signature:___________________________________________________________Date: ____________________